Tip #6: Keep in Touch With the Revenue Agent
Staying in touch with the revenue agent is critical. The practitioner can learn a lot, even if the agent does not come out and say that he suspects fraud or is in the process of making a referral to CI.
The careful and experienced practitioner should be able to sense when the audit has turned criminal. In this regard, one of the classic warning signs that a referral to CI is looming is that the civil audit has turned quiet.
Civil audits are conducted on a time line, which may vary from case to case. However, if the audit is not progressing, the practitioner needs to know why. Often, it is because an agent is swamped with other work or has been transferred. Or it could mean something far more sinister – that the civil agent has referred the case to CI.
When the civil audit turns quiet, the practitioner should touch base with the agent or his supervisor to find out what is going on, without, of course, tipping the agent that he is overly concerned about it.
Next: Tip #7: Dealing With the Agent
In accordance with Circular 230 Disclosure
As a former public defender, Michael has defended the poor, the forgotten, and the damned against a gov. that has seemingly unlimited resources to investigate and prosecute crimes. He has spent the last six years cutting his teeth on some of the most serious felony cases, obtaining favorable results for his clients. He knows what it’s like to go toe to toe with the government. In an adversarial environment that is akin to trench warfare, Michael has developed a reputation as a fearless litigator.
Michael graduated from the Thomas M. Cooley Law School. He then earned his LLM in International Tax. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of taxation make him uniquely qualified to handle any white-collar case.
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